Anti bribery and corruption.

Version 1 · Approved by the directors of AMS Administration Ltd on 1 September 2026 · Next review 1 September 2027

1. Our position

1. 1.1

   Roberts Crawford does not offer, give, request or accept bribes in any form, and does not allow anyone acting for us to do so. This applies in the UK and overseas.

2. Scope

1. 2.1

   This policy applies to directors, employees, consultants, contractors and anyone else acting on our behalf.

3. The law

1. 3.1

   The Bribery Act 2010 makes it an offence to offer or accept a bribe, to bribe a foreign public official, and for an organisation to fail to prevent bribery by people acting for it. Breaches can lead to unlimited fines and imprisonment.

4. Gifts and hospitality

1. 4.1

   Modest gifts and hospitality given or received in the normal course of business, such as a working lunch or tickets to a client’s show, are acceptable if they are reasonable, made openly and not intended to influence a decision.

2. 4.2

   Any gift or hospitality given or received worth more than £50 must be recorded in our gifts register and approved by a director.

3. 4.3

   We never give or accept cash, and never give or accept anything while a decision affecting the giver is pending, such as a negotiation we are conducting.

5. Facilitation payments and donations

1. 5.1

   We do not make facilitation payments to speed up routine actions. We make no political donations, and any charitable donation is made openly and recorded.

6. Raising a concern

1. 6.1

   Anyone who is offered a bribe, is asked to make one, or suspects that bribery has taken place must report it to a director as soon as possible. Concerns are handled in confidence and nobody will suffer for raising one in good faith.

7. Breaches and review

1. 7.1

   A breach of this policy may lead to disciplinary action, the end of an engagement and a report to the authorities. This policy is reviewed at least every two years.